Privacy Policy: Data Collection & Security

Effective Date: July 1, 2025
Company: Greenfoot Energy Solutions Inc. and its subsidiaries and affiliates (“Greenfoot”)

Overview of Greenfoot Energy Solutions' Privacy Practices

1. Introduction

This Privacy Policy outlines the privacy practices of Greenfoot Energy Solutions Inc., its subsidiaries, and affiliates (“Greenfoot”) concerning the collection, use, retention, disclosure, and security of personal information obtained from customers, credit applicants, employment applicants, and other individuals (“you” or “your”) in Canada.

This Policy has been developed in compliance with Canada’s private sector privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Personal Information Protection Act (British Columbia).

At Greenfoot, we are committed to protecting your privacy and maintaining the confidentiality and security of your personal information. We use this information to deliver the products and services you request and to better understand your needs and preferences—allowing us to provide the highest standard of customer service.

2. Personal Information We Collect

“Personal information” means any information about an identifiable individual, excluding business contact information when used solely for business communications.

Examples of personal information may include, but are not limited to:

• Identifying information such as name, address, telephone number, and email address.
• Information collected or generated to comply with legal and regulatory requirements.
• Social Insurance Number and/or other personal identifiers (e.g., date of birth) collected for credit checks.
• Credit reports, asset and liability information, and credit history.
• Account information, payment history, and records of transactions with Greenfoot.
• Financial dealings with third-party references or affiliates.
• Other personal information collected with consent or as permitted or required by law.

Note: Greenfoot uses a third-party provider for customer financing. We do not store or request Social Insurance Numbers directly. However, the third-party credit application process may require such information, and you should review their privacy policy as part of the application.

3. Collection of Personal Information

We may collect personal information in various situations, including but not limited to:

• When you request a quote, order, or purchase our products or services.
• When submitting credit or employment applications.
• When corresponding with us (electronically or otherwise).
• When participating in promotions or surveys.
• From public registries and databases.
• From credit reporting agencies and financial institutions.
• Through our affiliates, partners, and website visits (including automatically collected site data).
• Through other ongoing transactions or interactions with Greenfoot.

4. Use of Personal Information

Personal information will only be used for purposes to which you have consented, including:

• Identifying customers and their representatives.
• Developing and maintaining our business relationship with you.
• Reviewing credit applications and determining creditworthiness.
• Exchanging credit information with authorized parties.
• Detecting and preventing fraudulent or suspicious transactions.
• Meeting legal, audit, and regulatory requirements.
• Managing business operations, enforcing accounts, and collecting debts.
• Evaluating employment applications.
• Any other purpose consented to or as required by law.

Use Without Consent

Greenfoot may use or disclose personal information without consent when:

• Required by law enforcement or legal authorities.
• In emergencies threatening life, health, or security.
• For statistical or research purposes.
• When publicly available as defined by law.
• To prevent fraud or investigate breaches of law or agreement.

5. Disclosure and Transfer of Personal Information

Access to personal information is restricted to employees, officers, and directors who need it for legitimate business purposes.

Greenfoot may disclose personal information:

• To third-party suppliers, for products, services, or warranties you have requested.
• Within the Greenfoot Group, for fraud prevention, risk management, and verification purposes.
• To agents, service providers, or affiliates that process information on our behalf.
• In connection with business transactions (e.g., mergers, sales, or financing).
• To satisfy insurance, audit, or regulatory requirements.

All third parties handling personal information must protect it through confidentiality agreements or similar safeguards.

Permitted Disclosures Under PIPEDA

Greenfoot may also disclose personal information without consent to:

• Our legal representatives.
• Collect debts owed to Greenfoot.
• Comply with subpoenas, warrants, or court orders.
• Assist law enforcement or government investigations.

We will never trade, rent, or sell your personal information. When disclosure occurs, it will be done under strict privacy safeguards.

6. Disclosure and Transfers Outside of Canada

Some third-party service providers (including affiliates) may be located outside of Canada (e.g., the United States).
Personal information disclosed or processed outside of Canada may be subject to foreign laws.

7. Consent

Before or at the time of collection, Greenfoot will obtain express written consent for the stated purposes.
By signing a credit application or other form, you provide implied consent for Greenfoot to verify information with third parties (e.g., banks or credit bureaus).

You may withdraw consent at any time by submitting a written request to Greenfoot (see contact information below).
Withdrawal may affect Greenfoot’s ability to provide products or services.

8. Retention of Personal Information

Personal information is retained as long as necessary for business or legal purposes:

• Active files are maintained while the customer relationship exists.
• Inactive credit files (e.g., fully repaid or terminated) are retained for seven (7) years.
• Rejected applications are retained for up to two (2) years.

9. Accuracy

Greenfoot strives to keep personal information accurate and current.
Please notify us of any updates to your information.
Information in inactive files is not updated.

10. Safeguards

We employ physical, organizational, and technological safeguards to protect personal information, including:

• Secured file storage and limited physical access.
• Password protection, restricted access, and encrypted systems.
• Internal security policies and controlled data centers.
• Shredding of documents prior to disposal.

Only authorized personnel may access information for legitimate business needs.

11. Questions and Complaints

Questions or complaints regarding this Privacy Policy should be directed in writing to:

Greenfoot Energy Solutions Inc.
Attn: Laura Lee Faulkner, Marketing Manager
📧 Email: laura.leefaulkner@greenfootenergy.ca
📍 Address: 25 Gridless Lane, Moncton, NB E1A 9Z3
📞 Phone: (506) 953-1920

Greenfoot will investigate and respond to all verified complaints.
If you remain unsatisfied, you may contact the applicable Privacy Commissioner:

• Office of the Privacy Commissioner of Canada — www.priv.gc.ca
  30 Victoria Street, Gatineau QC K1A 1H3 | 1-800-282-1376
• Office of the Ombud (New Brunswick) — www.ombudnb.ca
  751 Brunswick Street, Fredericton NB E3B 1H8 | 1-888-755-6611
• Office of the Information and Privacy Commissioner for Nova Scotia — oipc.novascotia.ca
• PEI Information and Privacy Commissioner — https://www.assembly.pe.ca/
• Office of the Information and Privacy Commissioner (NL) — www.oipc.nl.ca
• Office of the Information and Privacy Commissioner for BC — www.oipc.bc.ca

12. Amendments to This Privacy Policy

This Privacy Policy is effective July 1, 2025.
Greenfoot may update this Policy periodically in response to changes in legislation or business practices.
All amendments will be posted on Greenfoot’s website and will apply to information collected after the revised date.

‍